ARP001013 Syrgis Performance Initiators Process Water Analysis

lead and zinc. The calculated limit for lead is 57.6 µg/l and for zinc is 132 µg/l. Syrgis reported 1.24 µg/l for
lead and 45.7 µg/l for zinc in the effluent.
Referring to the Department’s letter dated August 12, 2011, find:
Syrgis must sample only the process wastewater to verify compliance with the limits in 40 CFR 414.85 (Sub
Part H). In accordance with 40 CFR 414.111(b), since Syrgis does not have a lead or zinc bearing waste
stream listed in Appendix A, Syrgis must comply with the lead and zinc limits shown in the Department letter
dated August 6, 2010. To verify compliance Syrgis must sample the process wastewater before it enters the
pond and commingles with the stormwater. Syrgis’ process wastewater enters the pond in three different
lines. Syrgis must sample each line and may take grab samples (in lieu of flow proportional sampling). Syrgis
may composite the three samples in proportion to flow and submit only the one composite sample to the lab for
analysis.
The Department cannot verify that the submitted lead and zinc analyses were composited samples. Please
submit the calculation sheet which shows how Syrgis determined the percentages. This may be a handwritten
page, an Excel spreadsheet or a formal tabulated form. In either case, the submitted item must clearly show
how Syrgis determined the percentages.
Please submit the calculation information within thirty days of receiving this letter/email or by April 20, 2012
(whichever comes first). In the future, please submit the calculation information with each semi-annual report.
If Syrgis has concerns or requires more details, please contact Rufus Torrence at (501) 682-0626 or
torrence@adeq.state.ar.us.
Sincerely,
Rufus J. Torrence, Water Division Engineer
Encl: ADEQ Letters dated 9-4-2009, 8-6-2010 and 8-12-2011
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